Whose Data We Process

Why We Process Data

The reason for processing the Data is: to ensure SBMC is aware of who is using the building at any time; for the issue of keys to guests of residents or leaseholders and to keep a log of this issue; to ensure security of all stakeholders; for safety reasons; to keep residents/tenants/leaseholders up to date with various issues and activities in the building.

The lawful basis for processing the data is for the proper performance of the contract, whether that contract be a lease or tenancy agreement. You are under a contractual obligation to supply your Data to SBMC for the purposes listed in this Notice, limited to the Data listed in this Notice.

You do not need to give your consent to this processing and, as such, you cannot withdraw consent. Once the contract (lease/tenancy agreement) ends, there is no further requirement for SBMC to hold your data and it will be deleted (see below).

What Data We Process

The Data is limited to: name; phone number/s; email address. The Data is most often obtained from the individual which means that SBMC is a Data Controller in this regard. From time to time Data is obtained from Letting Agents (various), solicitors appointed by vendors or purchasers, or estate agents.

Third Parties We Share Your Data With

On the whole, Data is kept within SBMC and not shared, but the following organisations have access to the Data, for the following reasons:
• Fairweather Law – process leases and freeholds
• Lovell Blake – invoice for and collect ground rents
• IX Collective – manage the website and mailing system

No Data is transferred outside of the EEA. All suppliers have confirmed they process and hold Data within the EEA, in the UK in most cases.

Retention

We will hold your data for as long as you are a resident/leaseholder/tenant and for 12 months after that time unless you request otherwise. The reason we hold Data for 12 months after you end your contract is to ensure we can contact you in the event of any outstanding payments or contractual issues.

Your Rights

You, the Data Subject, have the following rights under the Data Protection Act 2018 (GDPR):
The right to:
• Be informed – this is the purpose of this Notice;
• Have access – you may ask for copies of Data we hold at any time;
• Have rectification – you may request we amend our Data at any time;
• Have data erased – you may ask for your Data to be erased but where we use it for the proper performance of the contract we can reject this request;
• To restrict processing – you may ask us not to use your Data in certain ways;
• Data portability – we do not provide Data for Data Portability so this right does not affect SBMC;
• To object – you have the right to object to your Data being processed;
• Around automated decision-making – we do not use automated decision-making.
If you feel your rights have been infringed you may make a complaint to the Regulatory Body, which is the Information Commissioner’s Office, at www.ico.co.uk. SBMC is a registered Data Controller with the ICO.

Third Parties Providing Data

From time to time Data is obtained from Letting Agents (various), solicitors appointed by vendors or purchasers, or estate agents.
Where this happens we will treat your data in the same way as outlined above.

Access to your Data

You may request access to your Data from the General Manager at any time. we will respond to your request, where we have been able to confirm your identity, within one month. There is no charge for this service.

Privacy Notice

This notice is provided on our website, via email when we send the Welcome Email and as a hard copy available on the concierge desk and given to visitors when we collect data from them.
If we obtain the Data from another source we provide this Notice when we send the Welcome Email which is no later than one month after taking possession of the Data. All residents, tenants and leaseholders get the Welcome Email and are on the mailing list to receive updates.
We have attempted to write this Notice in a clear and concise way. If you have any questions, concerns or feedback, please send them to [email protected]

Changes to the Notice

We regularly review and, where necessary, update our Privacy Notice.
If we plan to use personal data for a new purpose, we will update our Privacy Notice and communicate the changes to individuals before starting any new processing.